From last August 1st to mid-September, an obscure pro-Life group called National Campaign PAC reported spending over a million dollars in “independent expenditures” to defeat Hillary Clinton. During the same period, Voter Education PAC, listing the same treasurer and address, reported $160,000. Both supposedly spent the money convincing voters through phone banks.

At first glance, the PACs’ largess represented a huge boost to Donald Trump’s then-shaky campaign. But as with much of political fundraising’s murky realm, things may not be what they seem.

Spending seven figures over six weeks on political advocacy phone banking — most before Labor Day — is unusual. For comparison, during the entire Republican primary the Jeb Bush-supporting Right to Rise USA spent only $150,000 phone banking despite raising $118 million. Its biggest single expenditure was $21,100.

And if the Trump team wanted to drop an appreciative note for all the unsolicited support, they would be out of luck.

Despite reporting astronomical sums on advocacy through phone and direct mail schemes, the origin, operations, and ultimate beneficiaries of both PACs is a mystery. The likely explanation is that these unknown groups, who have taken pains to hide their identities and obscure their conduct, were running a massive moneymaking scheme off unsuspecting small donors that continues today.

What follows is the search for a “black ops” political-fundraising operation that has raked in millions but seems to have spent almost nothing on true political advocacy — candidate contributions and legitimate independent spending. As first noted by Casey Tolan of Fusion.net, small-dollar pro-Life true believers (and possibly other passionate electorates) are often victims of massive telemarketing schemes. The solicitors follow untraceable, high-pressure calls with shaming “invoices,” and misleading mailers.

Both PACs list their mailingaddress with the Federal Election Commission (FEC) as the same virtual office in Wilmington, Delaware. Neither has a readily available phone number or email; Voter Education lacks even a website. The paper trail ends with the PACs’ treasurer Ann Mattson. But she is also a ghost. She has no public phone number, no LinkedIn profile, no Twitter, no discernible online presence whatsoever. In fact, Ms. Mattson, the PACs, and the two vendors that exclusively serve them don’t seem to exist anywhere except required FEC filings.

Mattson created National Campaign PAC on May 15, 2014 by registering its FEC Statement of Organization (SOO). But calling it by its registered name is misleading. The PAC’s website, telemarketing calls, and mail operation describe it as “The Pro-Life Committee.” (The website listed on the PAC’s SOO, national-campaign.org doesn’t exist. thenationalcampaign.org, which aims to prevent teen pregnancy, and takes no position on abortion, is unrelated.)

“The Pro-Life Committee” doesn’t exist either, at least not officially with the FEC or IRS. National Campaign explains on disclaimers that “The Pro-Life Committee” is a “project” — a marketing ploy — of National Campaign PAC. Through this “project” National Campaign’s “Pro-Life Committee” brands itself as something that sounds an awful lot like “The National Right to Life Committee,” which has existed since 1968 and has 50 state affiliates and more than 3,000 local chapters.

Mattson created the other PAC, Voter Education, a year after National Campaign in March 2015. But despite receiving almost $1.3 million in contributions this past cycle, its public message is inaccessible. Voter Education’s SOO lists its website as voter-education.org. But that domain is currently for sale. The PAC is likely doing business as some yet discovered branding “project.” Like its sister PAC, Voter Education seems to exist mostly on paper.

The only online presence for either PAC is National Campaign’s prolifecommittee.org and a group of similarly worded splash-page websites. The main site features a large picture of a baby’s foot and a nondescript mission statement: “Our goal is straightforward: we hope to change hearts, change leaders and change laws until the day arrives when every child is welcomed into life and protected by law.” It also has a “Contact Us” box for messages. It lists no phone number or address.

The website’s only other tab is “Take Action” which has five subtabs: “Pray,” “Volunteer with a local pro-Life group,” “Support your local pregnancy crisis center,” “Volunteer for pro-Life candidates,” and “Vote.” All offer link-free generalities like, “Go to town hall meetings in your area and introduce yourself to your local elected officials. Ask them about their position on pro-life issues.”

The main website claims “national organizations” — presumably like National Campaign PAC — focus on “changing laws” and “electing candidates” while unnamed local organizations “distribute literature, circulate petitions, operate informational booths at community events, register voters, and recruit candidates.” It doesn’t say why an organization receiving over $7 million this cycle can’t also perform those chores.

Regardless, what has National Campaign done to “change laws”? The sum total seems to be pro-life-committee.net and prolifecommitteenews.com. Both are splash pages with single posts from February 1, 2015 where “The Pro-Life Committee” urges passage of an anti-abortion House Bill; one provides the text of the bill.

The other three websites are splash-page “advertisements” with standard pro-Life messages like “Babies belong in one piece” and “Eyes, Ears, Fingers, Toes, and a Beating Heart too.” Although the PAC describes them as “advertisements” or “advertorials” none list anywhere they appeared besides the URLs they occupy.

National Campaign claims its contribution go toward political action: “In 2014 we invested heavily in independent expenditures to support pro-Life candidates for the U.S. Senate.” Independent Expenditures are outside spending by political groups on communications that call for the election or defeat of clearly identified federal candidates. This cycle National Campaign has reported almost $1.5 million on such communications. But evidence and common sense suggests it is using a campaign finance law quirk to mask its telemarketing and direct mail operation.

One esoteric aspect of campaign finance law is the so-called “magic-words test.” If political communications use certain words like “elect,” “defeat,” “support” candidate X, they trigger heightened reporting. Thus, expenses for a telemarketing call that includes “Help us defeat Hillary Clinton” can arguably qualify as a reportable political expense even if the rest is a straight fundraising call for the PAC and no money actually goes toward “defeating Hillary Clinton.”

In other words, National Campaign seems to be reporting as candidate support the costs of hiring professional telemarketers whose sole job is to bring money into the PACs. They can then use those expense figures as the hook for further solicitations. “Last cycle the Pro-Life Committee spent over $1.5 million dollars against pro-choice Democrat Hillary Clinton” — even if 99% of that $1.5 million was the overhead for making the calls.

Given the enormous sums reported, that these are anything other than professional telemarketers hired and likely paid by how much they bring into the operation beggars belief. The solicitations may not even come from humans but a sophisticated computer program designed to respond to human voice cues.

Two vendors are the ultimate beneficiaries of the PACs’ operations. National Campaign spent $5,660,981 on expenditures other than its supposed candidate support. Of that, $5,540,094 (98%) went to either RFP Services or Political Issue Advocacy (PIA). But add the supposed candidate support and the numbers don’t change. That’s because all of National Campaign’s reported “independent expenditures” also went to PIA. Thus 98% of the over $7 million contributors gave to National Campaign went to the two vendors. And 98% of that money came from vulnerable small donors giving less than $200.

Voter Education spent $1,034,322 on vendors of which $930,656 (90%) went to RFP Services or PIA. Similar to National Campaign, RFP Services collected 100% of its reported independent expenditures. Thus 91% of everything the PAC spent went to these two vendors.

According to Open Secrets, RFP Services and PIA have only two clients: National Campaign and Voter Education.

RFP Services registered in Delaware in March 2014 and PIA registered in South Dakota two days later. Despite receiving millions the principals behind these two firms are unknown.

RFP Services has no website, no telephone number, and no online record of employing anyone. On FEC forms its address is its registered agent — a company responsible for accepting lawsuits on its behalf. PIA also has no phone number. A google search for the address listed on FEC forms lists four different firms selling virtual offices.

PIA’s website claims it “provides effective direct marketing and political consulting services to trade associations, candidate campaigns, political action committees and nonprofit organizations.” This appears to be false. Neither the political data clearinghouse Open Secrets nor the FEC Beta site has any record of PIA clients besides the two PACs. Its only contact is info@politicalissueadvocacy.com.

Of the tiny amount National Campaign does not give to RFP Services or PIA two other vendors stand out. One is PMK Accounting, which it paid $5,000 this cycle and more last cycle. Mattson listed her email address as annm@pmkaccounting.net on both PAC SOOs; she later changed them to a Gmail address. The pmkaccounting.net domain is currently for sale. On FEC forms, PMK lists the same virtual office as the two PACs. PMK Accounting appears to be another Mattson paper-only special.

National Campaign has also paid Morgan Meredith and Associates, a direct-mail operation in Sterling, Virginia, over $33,000 this cycle. MMA’s Client Page lists numerous politicians and respected nonprofits; National Campaign is not among them. MMA did not return a phone call inquiring about the work it does for National Campaign.

With the bulk of the PACs’ money going to two vendors and a spattering to others, candidates receive almost nothing. This cycle, National Campaign gave $10,000 of its total expenditures or 0.14% to federal candidates. Voter Education does little better at 0.72%.

Whoever is behind this scheme may have been inspired by a set of PACs with striking similarities operating in the early 2000s. Former George W. Bush Labor Secretary nominee Linda Chavez and her family created “The Pro-Life Campaign Committee” along with several other PACs catering to various constituencies. “The Pro-Life Campaign Committee” ran afoul of FEC reporting requirements and shuttered in 2009. According to an FEC press release: “The Committee… submitted amendments… that included millions of dollars in additional receipts and disbursements not initially disclosed. The majority of the increased receipts were unitemized contributions, and 90% or more of the increased disbursements were payments to Capitol Communications, Inc., a now defunct Arizona telemarketing firm contracted by the Committee to conduct fundraising.”

According to a contemporary Washington Poststory, “The Pro-Life Campaign Committee” raised $7.7 million and spent less than 1% on political activity. No direct evidence links National Campaign doing business as “The Pro-Life Committee” and Chavez’ “The Pro-Life Campaign Committee,” although both have ties to Arizona.

National Campaign’s practices were first exposed in 2014. Sharon Toborg, the treasurer of Vermont Right to Life Committee, received a National Campaign “Pro-Life Committee” telemarketing call and became suspicious when the caller couldn’t provide basic information. Live Action News later published a warning email from Toborg. People from all over sent her “Pro-Life Committee” materials and stories. She even filed a complaint with the Vermont Attorney General, which dismissed it for lack of jurisdiction.

Those materials along with message boards at Live Action News and other sites like Scam Guard, explain National Campaign’s tactics. All describe high-pressure calls that ask for pledges, perhaps $75. The amount shrinks if the target is uncertain or requests more information. The telemarketers, hired through RFP Services or PIA, may direct prospects to prolifecommittee.org but don’t answer inquiries beyond its vanilla postings. Targets often think the voice sounds computerized. The telemarketer identifying as “Jessica,” “Marylyn,” or “Erika” refuse to mail any materials without a monetary pledge because “postage is expensive.” They hang up if the target persists.

The calls — possibly from the Denver area although they could be spoofed — break down into two categories: One asks if the target is pro-Life, pro-choice, or undecided. The other identifies the person by first name, likely from a bought list. Targets that pledge get an “invoice” (at least one) postmarked from Arizona with copy about how they need to pay their bill like everyone else.

Once paid, a much lengthier letter arrives (the one I reviewed was 11 pages and signed by “Emma Smith, the Pro-Life Committee Volunteer Coordinator”) asking for double or triple the amount.

The mailer boldly asserts it is in the business of “saving lives.” “Think of the babies who will draw their first breath convinced by something you or I said or did or because leaders in their states pass laws to protect those lives.”

It describes National Campaign’s “crucial role” as “identifying potential champions for the cause” listing pro-Life candidates it supported. The mailer excludes the paltry $250 amount all candidates receive or that contributions compose less than one percent of disbursements. The mailer also notes another pledge will help National Campaign reach the public through:

• Direct mail and Internet ads to help spread the word about the humanity of unborn children
• Timely phone messages to potential voters
• Work with allies in churches and pro-life activists across the country
• And other efforts to spread the word in creative and persuasive ways

National Campaign through the two vendors undoubtedly has a huge direct mail and telemarketing operation somewhere. But it doesn’t seem to do anything but solicit contributions, while sometimes mentioning federal candidates to report “independent expenditures.” Also absent is evidence it has “worked with churches or pro-life activists.” And obviously “creatively and persuasively spreading the word” could mean anything or nothing.

Incredibly, the letter also assures, “We’re being very careful with our spending, not wasting it on expensive overhead or unnecessary expenses. We want to invest every penny we can in the big races to come and make sure your donation to us is money well spent.” (Emphasis in original.)

If National Campaign is proud of its life-saving work, no one there seems anxious to discuss it. Both an 800 number and an area code 202 number (Washington, D.C.) — supposedly the direct line of “Volunteer Coordinator Emma Smith” — have the same voice message where callers are urged to leave their contact information and assured their “prayers, suggestions, and support” are important. Messages left on both numbers were not returned. An email sent to Ms. Smith was also not returned.

Contacting Voter Education PAC, which has no available contact information was equally fruitless. Ann Mattson did not return phone calls or emails. I also emailed Political Issue Advocacy to no avail. RFP Services, similar to Voter Education PAC, has no available contact information. The registered agent for RFP Services and Political Issue Advocacy refused to give any contact information for them.

“People are very generous; the thought that the money that was meant to further the cause of life going into a black hole is sickening,” stated Ms. Tobor, before adding “let’s just call it what is, a scam.” National Campaign and Voter Education seem to be the product of people realizing millions were available taking advantage of well-meaning people who believe everyone deserves their life. Preying on the generosity of those people, a black hole has emerged that is enriching a few lives while saving none.